Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The HC dismissed the Revenue's appeal, finding no substantial question of law. The court relied on previous judgments regarding cloud service subscription payments, specifically holding that such receipts do not constitute "royalty" income under Article 12(3) of the India-Ireland DTAA and Section 9(1)(vi) of the Income Tax Act, 1961. The decision aligns with prior rulings in similar cases, effectively rejecting the Revenue's contentions and upholding the ITAT's original determination in favor of the Assessee.
The HC dismissed the Revenue's appeal, finding no substantial question of law. The court relied on previous judgments regarding cloud service subscription payments, specifically holding that such receipts do not constitute "royalty" income under Article 12(3) of the India-Ireland DTAA and Section 9(1)(vi) of the Income Tax Act, 1961. The decision aligns with prior rulings in similar cases, effectively rejecting the Revenue's contentions and upholding the ITAT's original determination in favor of the Assessee.
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